ML20245L565
| ML20245L565 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 06/29/1989 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20245L550 | List: |
| References | |
| 50-285-89-19, NUDOCS 8907050527 | |
| Download: ML20245L565 (29) | |
See also: IR 05000285/1989019
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SALP REPORT
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV l
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
50-285/89-19
OMAHA PUBLIC POWER DISTRICT
FORT CALHOUN STATION
May 1, 1988, through April 30, 1989
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I. INTRODUCTION
The Systematic Assessment of Licensee Performance (SALP) program is an
integrated NRC staff effort to collect available observations and data on
a periodic basis and to evaluate. licensee performance based upon this
information. The program is supplemental to normal regulatory processes
used to ensure compliance with NRC rules and regulations. It is intended
to be suff.iciently diagnostic to provide a rational basis for allocating
NRC resources and to provide meaningful feedback to the licensee's
management regarding the NRC's assessment of their facility's performance
in each functional area.
An NRC SALP Board, composed of the staff members listed below, met on
June 13,1989, to review the observations and data on performance, and to
assess licensee performance in accordance with NRC Manual Chapter 0516,
" Systematic Assessment of Licensee Performance." The guidance and
evaluation criteria are summarized in Section III of this report. The
Board's findings and recommendations were forwarded to the NRC Regional
Administrator for approval and issuance.
This report is the NRC's assessment of the licensee's safety performance
at the Fort Calhoun Station for the period May 1, 1988, through April 30,
1989.
The SALP Board for the Fort Calhoun Station (FCS) was composed of:
J. L. Milhoan, Director, Division of Reactor Projects
L. J. Callan, Director, Division of Reactor Safety
F. J. Hebdon, Director, Project Directorate IV, NRR
R. E. Hall, Deputy Director, Division of Radiological Safety and
Safeguards
T. F. Westerman, Chief, Reactor Project Section B
P. D. Milano, Project Manager, Project Directorate IV, NRR
P. H. Harrell, Senior Resident Inspector, Fort Calhoun Station
R. P. Mullikin, Project Engineer, Reactor Project Section B
The following personnel also participated in the SALP Board meeting:
B. Murray, Chief, Reactor Programs Branch l
R. E. Baer, Chief, Facilities Radiological Protection Section
W. C. Seidle, Chief, Test Programs Section
J. E. Gagliardo, Chief, Operational Programs Section
J. L. Pellet, Chief, Operator Licensing Section
H. F. Bundy, Reactor Inspector
N. M. Terc Emergency Preparedness Specialist i'
A. B. Earnest, Physical Security Specialist
L. L. Wheeler, Section Chief, Inspection and Licensing Program Branch
A. Bournia, Project Manager, Project Directorate IV, NRR
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A. Licensee Activities
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1. Major Outages
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The licensee shut down the plant for refueling on September 27,
1988, and returned it to service on January 29, 1989. This was
the only outage during this assessment period.
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2. License Amendments
During this assessment period, nine Technical Specification.
amendments were submitted by the licensee. Some of the more j
significant amendments are listed below: '
Revision of the reactor coolant system pressure-temperature
limits for heatup and cooldown
Changes for Cycle 12 operations.
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Change of minimum allowable temperature for the safety
injection and refueling water' tank.
Change of minimum requirements for operability of the raw
water system pumps.
3. Major Modifications
The major modifications made during this assessment period
include the following:
Removal of the first stage blading on the main generator
turbine
Extensive remodeling of the control room e../ elope
Installation of a reactor coolant system hot leg level
indicator
Installation of a diverse scram system
B. Direct Inspection and Review Activities
NRC inspection activity during this SALP evaluation period included
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50 inspections performed with approximately 6,065 direct inspection
hours expended. The inspections included an operational safety team
inspection (OSTI), maintenance team inspection, and safety
enhancement program team assessment.
C. Safety Enhancement Program Development and Implementation
During this assessment period, a Safety Enhancement Program (SEP) was
developed by the licensee. The SEP was generated by the licensee to
address the concerns identified as a result of an appraisal of the
i operation and management of the FCS by an independent contractor.
The independent appraisal was initiated in response to problems
l identified by NRC personnel during review of the instrument air event
that occurred in July 1987.
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In addition, the SEP also includes items identified by the NRC that
would improve the overall effectiveness of the operation of the
facility. The SEP encompasses a wide variety of activities related
to all the functional ~ areas discussed in this assessment report.
In April 1989 an NRC assessment team performed an. extensive review of
the status of the. licensee's implementation of the SEP items. As a
result of the assessment, the team noted that the licensee was making
satisfactory progress toward implementation of the SEP items. Some
SEP items may require additional management attention to ensure
completion in a timely manner.
The team also noted, for those items that have been substantially
completed,.that positive indications of improved performance were
apparent. However, the team noted that many SEP items had not been
" institutionalized" to ensure the commitments would be in effect
after the SEP is considered complete. The licensee subsequently
established a corporate SEP policy document and is in the process of
establishing policies and procedures which incorporate the SEP, where
appropriate. The licensee has demonstrated overall progress in
improving their capability to provide management leadership and
oversight of the diverse elements related to the conservative
operation of the FCS.
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The NRC will continue to monitor the implementation of the SEP.
Additional inspections will be performed during the new SALP period.
II. SUMMARY OF RESULTS
Overview
The SALP Board concluded that the management and operation of the FCS has
improved during this assessment period. The licensee issued, and is in
the process of implementing, the actions specified in the SEP. The
reorganization of the Nuclear Operations Division has resulted in
increased management attention to the day-to-day operations of the
facility.
Due to the large number of commitments made by the licensee in the SEP, a
large volume of work has been performed by the licensee. Based on reviews
made at the end of this assessment period, the Board felt that the licensee
was capable of handling the large number of commitments and still manage
day-to-day activities. However, the NRC is concerned with the licensee's
workload since many of the commitments are scheduled for completion in the
near future.
New issues, viewed by the SALP Board as not bound by the SEP, were l
identified. It was the Board's opinion that security management was so ;
focused on the implementation of the actions in the security upgrade !
program that dait activities of the security force were neglected. Also,
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the number of licensed operators remain relatively small.
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During this SALP period the licensee has improved their capability to
respond to plant events and technical issues.
Items of improvement included the completion of the training facility, {
overall plant appearance, establishment and staffing of the systems
engineering organization, and the establishment of the Nuclear Safety
Review Group that provides an independent review'of plant events and
anomalies.
However, the SALP Board concluded that there were areas where improvements
were needed. The licensee should ensure that all personnel follow all
procedures as written or initiate changes as appropriate.
Problems were also identified with the technical content of some
procedures. The technical adequacy of procedures was a concern. identified I
during the previous assessment period.
For the first time in 3 years, the program has been rated as satisfactory.
However, weaknesses continued to be identified with the licensed operator
requalification program.
The audits bei'ig performed oy QA were found to be compliance-oriented
instead of being performed on an operational safety approach.
The licensee's performance is summarized in the table below, alc.;g with
the performance categories from the previous SALP evaluation period.
Previous Present
Performance Performance
Cateoory Category
Functional Area (10/01/86 to 04/30/ 8 (05/01/88 to 04/30/89)
A. Plant Operations 2 2
B. Radiological Controls 3 2
C. Maintenance / Surveillance N/A* 2
D. Emergency Preparedness 2 2
E. Security 2 2
F. Engineering / Technical N/A* 2
Support
G. Safety Assessment / N/A* 2
Quality Verification l
H. Maintenance 2 N/A*
I. Surveillance 2 N/A* l
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J. Fire Protection 2 N/A* I
l K. Outages 2 N/A* i
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L. Quality Programs and 3 N/A*
Administrative Controls
Affecting Quaiity
M. Licensing Activities 2 N/A*
N,~ Training and Qualification 3 N/A*
Effectiveness
- NRC Manual Chapter 0516 was revised on June 6, 1988. This evaluation was
performed in accordance with the revised manual chapter. The major change
involved restructuring of the functional areas.
III. CRITERIA
Licensee performance was assessed in seven selected functional areas.
Functional areas normally represent areas significant to nuclear safety
and the environment. The following evaluation criteria were used, as
applicable, to assess each functional area:
A. Assurance of quality including management involvement and control;
B. -Approach to resolution of technical issues from a safety standpoint;
C. Responsiveness to NRC initiatives;
D. Enforcement history;
E. Operational events (including response to, analyses of, reporting of,
and corrective actions for);
F. Staffing (including management); and
G -. Effectiveness of training and qualification program.
However, the NRC is not limited to these criteria and others may have been
used where appropriate.
Based on the NRC assessment, each functional area evaluated was rated
according to three performance categories. The definitions of these
performance categories are as follows:
1. Category 1. Licensee management attention and involvement are
readily evident and place emphasis on superior performance of nuclear
safety or safeguards activities, with the resulting performance
substantially exceeding regulatory requirements. Licensee resources
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! are ample and effectively used'so that a high level of plant and
personnel performance is being achieved. Reduced NRC attention may
be appropriate.
2. Category 2. Licensee management attention to and involvement in the
i performance of nuclear safety or safeguards activities is good. The
licensee has attained a. level of performance above that needed to
' meet regulatory requirements. Licensee resources are adequate and
reasonably allocated so that good plant and personnel performance is
being achieved. NRC attention may be maintained at normal levels.
3. Category 3. Licensee management attention to and involvement in the
performance of nuclear safety or safeguards activities are not
sufficient. The licensee's performance does not significantly exceed
that needed to meet minimal regulatory requirements. Licensee
resources appear to be strained or not effectively used. NRC
attention should be increased above normal levels.
IV. PERFORMANCE ANALYSIS
A. Plant Operations
1. Analysis
The assessment of this area consists of the activities of the
licensee's operations staff. This functional area includes
activities such as plant startup and shutdown, power operation,
system lineups, logging plant conditions, responding to
off-normal conditions, manipulating-the reactor and auxiliary
controls, plant housekeeping, and control room professionalism.
This area was inspected on a continuing basis by the NRC
resident inspectors and periodically by other NRC inspectors.
An Operational Safety Team Inspection (OSTI), performed indepth i
and comprehensive reviews of the performance of operations
personnel, organizations providing support to the operations
staff, and management oversight of the operation of the FCS.
The plant was operated during this assessment period without an
unplanned manual or automatic reactor trip. The licensee has
not experienced an automatic or unplanned manual trip since
August 1986. On September 27, 1988, the plant commenced a
refueling outage, after completing a continuous power operating
cycle of 477 days that started on June 8, 1987.
The licensee maintained a highly experienced and knowledgeable
group of licensed senior reactor operators (SRO) and reactor ,
operators (RO). The operations staff was stable during this 1
assessment period with a very small turnover rate of licensed
on-shift operators. Staffing was at a level that permitted the
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licensee. to maintain a six-shift ro';ation, except- for vacation
schedules in the summer months. The'use of overtime has not-
been-a concern.-
' The licensee's staff currently includes 27 individuals
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e (14 on-shift and 13 staff personnel) that hold an SRO license-
q -and 10 (8 on-shift and 2 personnel in training) individuals.that
hold an R0 license. However, compared to other. plants in
Region IV,.this represents a.small pool of licensed on-shift
personnel. The size of the licensed staff was a concern to.the
NRC.during the previous assessment period and it continues to be-
a concern even.though the licensee's operating staff increased
by four SR0s and .two R0s during this assessment period. The
licensee is in'the process of adding three additional'R0s to the
operator staff and upgrading two R0s to SR0s. The additional
licenses and upgrades are scheduled to be completed in 1989.
The increased number of licensed operators was viewed by the
Board as a safety enhancement., This would provide an increased
pool.of' qualified operating staff to respond to operating
challenges, as well as an increased personnel source for other
positions within the OPPD nuclear divisions.
The licensee has increased the number of authorized operations.
positions (licensed and nonlicensed operators) from 50 in early ~
1988 to the current level of 65. positions. The. licensee added
11 personnel during this assessment period and anticipates that
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the remaining 4 positions will be staffed by the end of 1989.
During this assessment. period, licensed on-shift operators
exhibited a strong'and dedicated commitment toward the.
performance of their duties. Operations personnel developed and
issued their own professional code of conduct to formally
establish the elements that' constitute the level of. performance
expected of all professional operators. Plar.t operators
(licensed and nonlicensed) were aware of plant conditions and
work' activities being performed under their control.
On a number of occasions during this assessment period,
operaticns personnel responded to plant perturbations and
prevented the perturbations from leading to more significant
problems that may have caused challenges to safety-related
systems.
A number of problems were identified during this assessment !
period that required management to address the operability of
equipment and components. The problems were identified during
- activities related to the licensee's reconstitution of the
l- design basis, self-initiated reviews, and inspections performed
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by NRC personnel. During review of each item, it appeared that
management took a conservative approach when addressing
problems.
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The shift supervisors were noted to be involved with the- !
management decisions made on the determination of equipment
operability. The involvement of shift supervisors in the
decision process, as well as the conservative approach for
determination of equipment operability by management, was not
evident during previous assessment periods.
The licensee's reporting of plant events and anomalies was
reviewed on a number of occasions to verify compliance with
10 CFR Parts 50.72 and 50.73. For each case reviewed, it was
noted that the reports were timely, conservatively implemented,
and provided the appropriate level of detail.
During this assessment period, isolated problems were identified
with the performance of the operations staff. Most notable was
identification of occasional failures by operations personnel to
use, follow, and change procedures when required. The use of
procedures has been an ongoing concern during this assessment
period, not only in the. operations department, but in the other i
FCS organizations. Although no specific problems have resulted
from personnel failing to follow procedures, it is necessary
that management create an attitude and culture for all facility
personnel that ensures procedural compliance is established,
implemented, and maintained for optimum safe operation,
maintenance, and management of the FCS. A contributing factor
appears to be that personnel are extremely familiar with the
evolutions they perform and do not rely on the instructions
provided in procedures to complete an evolution. Also related
to this concern, is a problem that many safety-related
procedures do not provide the appropriate level of detail for
performance of a plant evolution. It is recognized that 6he
licensee'is currently involved in an ongoing procedures upgrade
project.
During performance of the OSTI, NRC inspectors noted that access
to the control board area was not being adequately controlled.
Personnel were randomly entering the controls area without an
obvious reason. The licensee took corrective actions during the
outage by extensive modification of the control room envelope.
The shift supervisor's office was moved from the rear of the
control room to just inside the main control room entrance.
Requirements for entry into the controls area was established
and implemented by prohibiting entry without the permission of
an on-shift licensed operator.
During previous assessment periods, concerns were identified
with the status of plant labeling, housekeeping, and appearance.
The licensee has completed repainting approximately 40 percent
of the plant (both safety- and nonsafety-related areas),
established a scheme for color coding each plant system,
initiated a new component labeling program using tags that
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contain the component number and identification. description,fand
upgraded efforts to improve plant cleanliness. . .During this
assessment per1od, only a few. items were identified where
housekeeping activities needed additional management' attention.
Additional tours of the plant by management and other. personnel-
are needed. During tours of the plant by NRC inspectors,
numerous items were identified that did not conform to
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. established requirements or.that required' additional management
attention.
- J In the previous assessment period, a concern was identified with
.. the development.and implementation of career paths for licensed
on-shift operators. The licensee has initiated actions to
address'this concern.
2. Performance Rating
The licensee is considered to be in Performance ' Category 2 in
this functional area.
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3. Board Recommendations
a. Recommended NRC Actions
NRC inspection effort in this area should be consistent
with the core inspection program. Additional attention
should be focused on monitoring'the procedural compliance
of the operations staff.
b. Recommended Licensee Actions
Licensee management should devote additional attention to
the apparent problem of' personnel not following procedural-
requirements. Although this area is currently being
addressed by an item contained in the SEP, it does not
appear that the actions are being implemented in a timely
manner.
In addition to SEP items, additional management attention
should be provided for the hiring and training of personnel
to become licensed operators.
B. Radiological Controls
1. Analysis
The assessm?nt of this functional area consists of activities
directly related to radiological controls, including
occupational radiation safety (i.e., occupational radiation
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. protection, radioactive materials, contamination controls,
radiation' field control, radiological surveys and monitoring,
Land as low as reasonably-achievable programs);. radioactive waste
' management (i.e., processing ~and onsite storage of gaseous,
liquid, and solid waste); radiological- effluent controls and
monitoringLincluding gaseous and liquid effluents, offsite dose
calculations, radiological environmental monitoring,. and
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confirmatory measurements; and-transportation of radioactive
materials (i.e., procurement of packages, preparation- for
shipment, periodic' maintenance of packagings, and
point-of-origin safeguards activities).
The occupational radiation' safety program was' inspected'six
times,Lincluding. two team inspections, during this assessment .
period by NRC region-based radiation specialist inspectors, in
addition to the routine inspections performed by:the NRC
resident. inspectors. Violations involving the failure to. follow
procedures and failure to submit accurate personnel monitoring
data were identified during this assessment period. An
enforcement conference was held.in the NRC's Region IV office on
February 24,.1989, to discuss four violations identified during- -
a January'1989 inspection. The 1.icensee also visited the
Region IV office on November 18, 1988, to provide status updates
on the radiation protection enhancement program.
One of-the items discussed during the enforcement conference'was
an. event'.where the licensee identified that. individuals entered
a high radiation area without the proper dosimetry. As a result
of this event and previous events of this nature, the plant
manager instituted a stop-work order for all activities in
radiological controlled areas (RCA). All: personnel were
required to attend a special training class on radiological
protection practices prior to being allowed to reenter the RCA.
In addition, the licensee also extensively revised the
administrative controls for the generation and issuance of
radiation work permits. The actions taken by management were
considered to be proactive, conservative, and timely.
The licensee has initiated a radiological protection enhancement
program that addresses the upgrade and improvement of all
functional areas of the radiological controls area,
identification'of major milestones, and establishment of
completion dates for each item addressed by the program.
Corporate and site management have increased their level of
oversight responsibilities in an effective manner with respect
to the functioning of the radiological controls program. An
extensive reorganization of the radiological and chemistry
organizations was implemented. The two groups were previously
under one supervisor, but the organizational change provided a
supervisor for each group. This organizational change has
increased the visibility of each group and has provided an
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own organization. The licensee has'also increased the staffing
in each group. Personnel staffing in the radiological controls
y area has been increased from 22 to 54 and, in the chemistry
- area, from 13 to 19. The experience level and technical
qualifications of the occupational radiation safety staff has
been significantly improved. The licensee's person-rem exposure
for 1988 was about 20 percent below the PWR national average.
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The turnover rate with the radiation protection group was below
L 15 percent.
The approach to the resolution of technical issues has been
demonstrated to be technically sound and thorough. in almost all
cases. Staff perscnnel have been supplemented with experienced
contractor personnel to assist in the development and
improvement in the areas of training, dosimetry, respiratory
protection, industrial health, and radwaste management.
Radiation protection technical training programs have improved
over the previous assessment period. A plant systems training
program has been implemented for radiation protection personnel.
The licensee's radiochemistry and water chemistry programs were
inspected once during the assessment period. No violations were
identified. Confirmatory measurements were performed on water
chemistry samples and the results were found to be within the
expected industry performance levels. The licensee's level of
performance in this area appears to be satisfactory.
The licensee's transportation program was inspected once during
this assessment period. No violations were identified. The
licensee has maintained an adequate program during this
assessment period. The licensee shipped, by rail, two large
contaminated reactor coolant pump motors to an offsite vendor
for overhaul and testing. The attention provided by the
licensee's staff to detail and quality control surveillance
involved with this shipment indicated that management
involvement and contro'l of activities were well established,
controlled, and implemented.
The radiological waste management area was inspected once during
this assessment period. No violations were identified. The
licensee's control of liquia and gaseous effluents and the solid
waste processing program is a well managed program area. The
radiological environmental monitoring program was not inspected
during this assessment period. ;
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The licensee has supplemented the routine quality assurance j
audit functions performed by corporate personnel with appraisals I
performed by consultants. These appraisals have been directed
at both worker performance and management involveinent to improve
the radiation protection program.
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The licensee's performance in the radiological controls area has
steadily increased in effectiveness, During the previous
assessment period, concerns were identified with management
oversight of the activities related to this functional area and
the performance of inadequate audits. It appears that the
licensee has adequately addressed these concerns. No problems
were identified in these areas during this assessment period.
To-improve the performance of the radiological protection and
chemistry groups, the licensee commenced construction of a
chemistry / radiological protection lo.cker room and a radiological
waste storage building.
The licensee is actively addressing the concerns and problems
identified in this functional area through the issuance of items
in the SEP.
Overall, corporate and plant management attention to the
concerns identified in this functional area has been evident. !
It appears that the licensee is identifying their own problems
and are taking actions to correct the problems. The root cause i
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identification of problems has been adequate but results in
occasional repetition of events. Licensee management is
actively recruiting experienced personnel to fill the vacant
positions remaining in their staffing upgrade efforts. The
resolution of technical problems is generally timely and
improvements are generally sound.
2. Performance Rating
The licensee is considered to be in Performance Category 2 in
this functional area.
3. Board Recommendations
a. Recommended NRC Actions ;
The NRC inspection effort in this area should be consistent
with the core inspection program.
b. Recommended Licensee Actions
The licensee should continue the on going efforts toward
improvement in the radiological controls area by completion
of the implementation of the radiological protection
enhancement program actions identified in the SEP, and by
continuing to stress improvement in procedural compliance
and self-identification of problems.
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- C. Maintenance / Surveillance-
1. Analysis- 1
This functional area includes all activities associated with
either diagnostic, predictive, preventive, or corrective
maintenance of plant structures, systems, and components;
procurement, control, and storage of components, including
qualification controls; installation of plant modifications; and
maintenance of the plant physical condition. It includes
conduct of all surveillance (diagnostic) testing activities'as
well as inservice testing and inspection activities.
This functional area was periodically inspected by NRC
region-based inspectors and on a routine basis by the NRC
resident inspectors. In addition to the routine inspection
program, three special team inspections were performed. An OSTI
was performed to evaluate the adequacy of support being provided
to operations personnel in the arus of maintenance and
surveillance. A maintenance team inspection (MTI) was performed
to provide an indepth and comprehensive review of the ,
maintenance organization and their activities. The j
nondestructive examination (NDE) mobile van from NRC's Region I
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office was on site to perform an inspection focused on the
licensee's inservice inspection activities.
During this assessment period, the licensee maintained a very
stable and well qualified maintenance work force with little
turnover,'except for the I&C area. The turnover rate in the I&C
area has been higher than any other area and has resulted in an
overall decrease in the experience level (average of
approximately 2 years) and~ effectiveness in this group. No i
maintenance-forced outages were experienced during'this ,
assessment period. The skill and long-term stability of the l
craft, with the exception of the I&C group, are considered
strong points which has overcome the poor quality of procedures.
The OSTI team noted a positive, professional attitude of I
maintenance personnel toward the performance of their
responsibilities. In the area of surveillance, the licensee has
assigned a dedicated individual to track the timely completion
of surveillance tests.
The licensee has taken actions to increase the level of staffing
for the maintenance group during this assessment period. An
addition of 25 personnel has been made to the staff. The
personnel were added to the crafts and maintenance planning
staffs.
To improve communications between all plant and corporate
organizations, the licensee issues a daily plan-of-the-day (POD).
The POD has been a significant factor in the distribution of
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information related to maintenance and surveillance activities.
The POD provides a prioritized. listing of the maintenance and i
surveillance activities to be performed each day. At the POD i
meeting held each morning, a review of the~ previous day's j
activities is performed to verify that all previously assigned
activities were completed. Since the POD was initiated, problems
have not occurred with the timely completion of surveillance
tests.
The licensee has reduced the backlog of nonoutage, corrective
maintenance orders (MO) to approximately 3500 hours0.0405 days <br />0.972 hours <br />0.00579 weeks <br />0.00133 months <br />. At the l
beginning of this assessment period, the M0 backlog was
approximately 4500 hours0.0521 days <br />1.25 hours <br />0.00744 weeks <br />0.00171 months <br />. This action represents a concentrated
effort by the licensee to provide attention to components and
equipment requiring maintenance. The maintenance group
prioritizes the work based on the safety significance of the
component or equipment.
During performance of the OSTI, problems were noted with the
administrative controls of the M0 process. The problems
included activities related to the preparation, implementation,
'
and review of MOs.
The MTI indicated that, while the maintenance program at the FCS
was viewed as weak in areas, the SEP (when fully implemented)
appeared to address all areas of concern. In particular, the
MTI results indicate that, while the program is being improved,
- implementation, as could be expected, lags program development
activities.
e
The MTI noted that the licensee did not have programs fully
implemented to address the root cause and failure analysis
process. It appeared that adequate predictive and preventive
maintenance programs could not be effectively established
without comprehensive root cause and failure analysis processes.
These processes are currently being developed.
The performance of surveillance testing by the licensee was
reviewed on a routine basis by the NRC resident inspectors and
by NRC region-based inspectors. The results of an inspection
performed during plant startup indicated that the licensee had
implemented an adequate startup testing program staffed by
experienced personnel. However, the NRC inspectors noted that
the licensee did not implement an independent review for the
processing of data obtained from core physics testing. It
appeared that the licensee relied on the capabilities of each
individual without the benefit of an independent data check. As
a result, the NRC inspectors identified calculational errors in
the licensee's physics testing results.
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During this assessment period, problems were identified with
procedural compliance. As discussed in the functional area of
Plant Operations, the licensee has experienced problems with
'
procedural compliance by all onsite organizations. It appears
that this problem exists due to over familiarity of personnel j
with the tasks they are performing.
I
In the last assessment period, concerns were identified with "
scheduling and implementation of surveillance tests based on the
issuance of TS amendments. It appeared that the licensee
provided adequate corrective actions for these concerns as no
problems were noted in these areas.
Overall, management involvement and control of maintenance and
surveillance activities indicated evidence of prior planning and
' identification of priorities. Corrective actions were generally
taken to address problems identified by the licensee and the !
NRC. Pracesses for root cause and failure analysis are under
development and full implementation has not b*en achieved.
2. Performance Rating
The licensee is considered to be in Performance Category 2 in
this functional area.
3. Board Recommendations
a. Recommended NRC Actions
The NRC inspection effort in this functional area should be
consistent with the core inspection program. Additional
inspections by NRC resident and region-based inspectors
should focus on the performance of personnel conducting
maintenance and surveillance field activities. i
b. Recommended Licensee Actions
In addition to the SEP, licensee management should focus j
their attention on cnsuring that personnel performing i
safety-related activities complete the tasks in accordance f
with the procedures, as written, or change procedures when 1
req ui red. i
)
1. Analysis
This functional area includes activities related to the
I
establishment and implementation of the emergency plan and
implementing procedures, such an onsite and offsite plan
development and coordination, support and training of onsite and
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offsite ' emergency response organizations, licensee performance
.
during exercises and actual events that test emergency plans,
l administration.and~1 implementation-of the plan (both during.
drills and . actual' eve 9ts), notification, radiological exposure
control, recovery, protective actions, and interactions-with
onsite and'offsite emergency response organizations during ; l
exercises and actual events.
l
Two emergency preparedness inspections'ere w included in this
assessment. One inspection consisted of observation of the
annua 1' emergency exercise and the'other inspection reviewed the
operational status of the emergency preparedness program. The
second inspection to review the operational status of the:
emergency. preparedness program was completed approximately two,
weeks after the end of the assessment period. Region IV-
management made .a decision to delay this inspection based on '
scheduling conflicts.
Significant weaknesses were identified during the 1988 emergency
preparedness exercise. During the exercise, the NRC inspection
' team identified several instances of failure to establish and
maintain adequate information flow, inappropriate assignment of
priorities, lack of adequate control and coordination,
inadequate appropriation of responsibilities, failure to
properly classify an emergency condition, poor reentry team
briefings, poor personnel accountability methods,' failure to
follow procedures, and deficient radiological controls. These'
findings indicated that the licensee needed to make substantial
improvements'in their emergency response ' program.
A meeting was held at the Region IV office on July 28, 1988.
This meeting was held to discuss the exercise weaknesses
identified during the July 1988 exercise. The licensee's
positive response to NRC initiatives was evident in their
commitment to improve their ertire emergency preparedness
program. The licensee has added a permanent onsite supervisor
and a clerk to their emergency planning staff. The licensee has
maintained an adequate emergency planning staff to permit
implementation of their program. The licensee is presently
pursuing the development of a revised training program for
emergency response personnel; a complete evaluation, review, and
rewriting of their emergency plan implementing procejures; and !
an evaluation of the structure of their emergency response i
organization to make it consistent with procedures and training.
The licensee has promptly submitted changes to their emergency
,
plan and implementing procedures to the NRC and has maintained a
working contact with offsite support agencies. Their emergency
facilities were found to be well equipped. Interviews conducted
during the last inspection with emergency responders indicated
that their training program was effective since emergency
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1
response personnel demonstrated adequate overall knowledge of
their duties and responsibilities. The licensee has improved
their independent audit program by adding auditors from another j
nuclear facility that have experience in emergency preparedness. j
A review of their last audit, conducted in March 1989, showed ]
that quality assurance auditors performed an independent audit 1
with adequate scope and depth.
2. performance Rating
The licensee is considered to be in Performance Category 2 in
this functional area.
3. Board Recommendations )
,
a. Recommended NRC Actions
The NRC inspection effort should be consistent with the
core inspection program and attention should be focused,
during the 1989 exercise, on followup of corrective actions
for the previously identified weaknesses.
b. Recommended Licensee Actions
l
Licensee management should continue to provide strong
support for the emergency preparedness program. The
licensee should closely monitor remedial actions for
weaknesses identified during the 1988 exercise to prevent
recurrence.
E. Security
1. Analysis
This functions 1 area includes all activities that ensure the
security of the plant including all aspects of access control,
security background checks, safeguards information protection, ,
and fitness-for-duty activities and controls.
Inspections were conducted by region-based physical security
inspectors on five occasions during this assessment period and
on an ongoing basis by the NRC resident inspectors. Violations l
were identified that involved inadequate compensatory measures, {
failure to maintain isolation zones free of obstructions, i
failure to report security events, failure to control safeguards
information, inadequate access controls, and inadequate control
of keys. These types of violations have been identified during
previous assessment of the security program. Management
L meetings were held with licensee representatives in the
'
Region IV office on September 22, 1988, and January 19, 1989, to j
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discuss the' security' program that was developed by the licensee , 'f
to address.the identified security problems.
The licensee has been. involved.in a major. upgrade of the entire
security program during this assessment period. In June 1988,
the licensee hired.a' consultant to perform an indepth review ofL .
the= security program. -The consultant identified significant )
. problems related to security staffing,' training, qualified {
first-line supervisory personnel, personnel communications, -1
quality assurance surveillance 'of security programs, security I
program documentation, and personnel morale. Since the review l
was completed, the licensee has initiated a comprehensive.
program to correct the' identified problems. .The licensee has
not provided strong oversight.and closely monitored the
scheduled completion dates of upgrade activities being
accomplished by' contractors.
I
The security upgrade program involved a major organizational
restructuring of. the security organization. The changes have
been too recent to evaluate their impact. The selection of
first-line supervisors was completed in late February 1989.
These first-line supervisors are security shift supervisors that
are assigned to each security shift. This irdividual provides
the on-shift presence of a management representative and serves
to provide a continuous oversight of the performance of the'
~
security force. This approach has resulted in improved
performance by each security shift. Two key security management
positions were filled in late March 1989.
Besides the addition of a security shift supervisor to each
shift, the licensee has also added 35 personnel to the security
staff. All security personnel are presently armed individuals.
Having a staff of armed guards has appeared to solve'some of the
licensee's problers related to inadequate compensatory measures.
The lirmsee's focused attention to the security upgrade effort
may hav'e distracted licensee management's attention from the
dayeto-day operations of the security force and contributed to
many of the problems and violations identified during this SALP
period. Many of the violations were self-identified and the .,
effectiveness of the licensee's corrective actions indicated '
positive results within the last 3 to 4 months of this
assessment period. The licensee's solutions to problems have
been technically sound, but completion of the upgraded programs
and systems has been slow. The licensee has been generally
responsive to NRC initiatives.
1
At the end of this assessment period, the licensee appeared to )'
have a sufficient number of supervisors, fully qualified
security officers, and support personnel assigned to the
security organization to comply with the appropriate regulatory
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requirements. However, the transition to a fully-staffed
security organization has not been completed. During the past
3 to 4 years, there has been a high turnover rate in the
managers for the security program. These frequent management
changes have resulted in the failure to establish a well
organized security program. Notwithstanding the problems
associated with the security program, the security force has
operated at an acceptable level of performance. The training
and qualifications of the security staff appear to be adequate.
The licensee's attention and involvement with nuclear security
was evident as demonstrated by program improvements concerning
the classification, logging, and reporting of security events in
the first quarter of 1989.
On April 24, 1989, the licensee implemented a fitness-for-duty
program that includes random drug and alcohol testing for all
licensee and contractor personnel that have onescorted access to
the nuclear facility. No personnel problems with respect to the
licensee's fitness-for-duty program were identified during this
assessment period.
2. Performance Rating
The licensee is considered to be in Performance Category 2 in
this functional area.
3. Board Recommendati-n,
a. Re_ commended NRC Actions
The NRC inspection effort should include the core
inspection program along with regional initiatives to
inspect the security program upgrade activities.
b. Recommended Licensee Actions
Licensee management should continue to provide strong
support to the implementation of the corrective actions
identified in the security upgrade program. Close
monitoring of the completion of the upgraded security
hardware program currently in process may be required to
ensure timely completion. Additional attention should be
provided by management to continue to ensure effective
day-to-day operation of the security force.
F. Engineering / Technical Support
1. Analysis
The assessment of this area includes all licensee activities
associated with the design of plant modifications; engineering
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and technical support for operations, outages, maintenance,
testing, surveillance, and procurement activities; training;
configuration management; and fire protection / prevention.
This functional area was inspected on an ongoing basis by the
NRC resident inspectors, by NRC region-based personnel, and by
the OSTI and MTI teams.
The licensee has taken actions to strengthen their design change
control process during this assessment period. The changes made
by the licensee were performed based on the results of a Safety.
System Outage and Modification Inspection (SSOMI) performed in
1985. No problems were noted with the modification instructions
that were issued and the modifications installed during this
assessment period. The modification packages reviewed by NRC
personnel were complete, concise, and contained the appropriate
elements.
During this assessment period, the plant entered a ' refueling
outage. During reloading of fuel assemblies, one assembly
became stuck. Operations personnel acted quickly to free the
stuck assembly. The NRC resident inspectors observed numerous
selected activities of the refueling evolutions and noted that
operations personnel performed the refueling tasks in a
professional manner.
The licensee inspected the tubes in both steam generators using
eddy-current testing techniques during the refueling outage.
The testing indicated that no tubes required plugging. This was
the second refueling outage in a row where no steam generator
tubes were plugged. The principal reason for not experiencing
problems with steam generator tubes appears to be due to the
strict secondary water chemistry program established by the
licensee.
In the previous assessment period, the licensee experienced a
major event where water from the fire water system was
inadvertently introduced into the instrument air system. The
introduction of water caused the operability of the large number
of components and equipment serviced by instrument air to be
questionable. As a result of the event, the licensee identified
64 corrective actions to be taken to verify that the instrument
air system met the design basis, as described in the Updated
Safety Analysis Report. During the refueling outage, the
licensee completed all of the remaining actions related to the
instrument air system upgrade.
During this assessment period, the licensee initiated a program
to reconstitute the design basis for the safety-related systems
installed at the FCS. As a result of the licensee's efforts, a
number of design basis problems have been identified by the
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engineering group. The licensee's response to the problems has
been timely, conservative, and effective. Other technical
issues were addressed by the engineering organization in
o addition to the items identified by the reconstitution program
and the technical resolution of these. items was timely and
adequate in each case.
The licensee established an onsite systems engineering group
during this assessment period. The group was established to
assign specific systems to an individual that serves as the
primary interface for all actions performed on the individual's
assigned system. The individual is responsible for oversight of
actions on each system such as maintenance, surveillance,
modification, operation, and testing. The establishment of the
systems engineering approach creates a systems expert for each
of the systems. This approach has proven to be highly effective
in the resolution of identified system problems.
The staffing of the systems engineering group was supplemented
by contractors at the end of the assessment peried.
Approximately half of the engineers were in training that was
specifically established for the engineers. The licensee
increased the staffing for all engineering organizations from
123 to 213 personnel during this assessment period.
During performance of the OSTI, NRC inspectors identified
problems with the method used by the engineering organization to
control the installation of temporary modifications. The
licensee took immediate actions to resolve the problems.
Problems with the technical content of procedures were
identified by the NRC resident and region-based inspectors, and
the MTI and OSTI teams. During the previous assessment period,
concerns were also identified with the technical content of
procedures.
The licensee has established a program for upgrading all
safety-related procedures, including technical' content. This i
program is currently in progress. .The program was established '
to revise all safety-related procedures, approximately 3000, to
provide the proper technical content, verify that the procedures
can be performed as written, and perform a validation and
verification by the procedure user.
A number of recurring problems in the fire protection area were
identified, such as not establishing hourly fire watch patrols
when required and the inoperability of fire barriers. In the
early part of 1989, the licensee hired a consultant to perform i
the functions of a dedicated fire protection engineer and to
address fire protection problems. On two occasions during this
assessment period, fires occurred in the plant that required the l
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response of the fire brigade. In both cases, the fire brigade
responded in a timely manner and quickly extinguished the fire.
A review of welding and NDE activities indicated that the
licensee Aas taken actions to develop, issue, and implement a
l. compreher,sive welding program, and to add experienced personnel
l to the staff with welding expertise. Although concerns were
! identified with the welding program during this assessment
period, the concerns appeared to be minor.
During this assessment period, the licensee's-licensed operator
requalification program was rated satisfactory; however, the
margin of success was slight in that the failure of one
additional individual of the 13 operators taking the
requalification examination would have caused the program to be
rated unsatisfactory. This was the first time in the last
3 years that the program had been rated as satisfactory.
Problems in the area of licensed operator training continue to
be identified by NRC personnel involving training mater 41,
operator input to training, and analysis of training needs. It
appears that management responsible for the support of operator
training continues to wait for the NRC to identify and solve
problems, rather than taking a proactive approach toward
identification and resolution of problems.
The replacement examination program exhibited good performance.
Of the ten individuals that took replacement examinations, all
ten passed and were licensed.
A review of the licensee's nonlicensed training programs was
performed by an NRC region-based inspector. The review noted
that it appeared that the licensee had implemented a
comprehensive and effective training program. However, the OSTI
team identified concerns with electrical safety training for
plant personnel and those concerns are currently being addressed
by the licensee.
The licensee completed the construction of a new training center
in January 1989. The training center represents a substantial
investment to upgrade the training facilities for the FCS. The
licensee is in the process of constructing a plant-specific
simulator, which should be fully operational by June 1990.
2. performance Rating
This licensee is considered to be in Performance Category 2 in
this functional area.
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3. Board Recommendations
a. Recommended NRC Actions
The NRC inspection effort in this area should be consistent
with the core inspection program. Additional inspections
should be performed in the area of licensed operator
training to verify that actions are being implemented to
improve the quality of the program. In addition, the NRC
,
should monitor the performance of the licensee during the
transition period when contractor personnel are phased out.
Also, further inspections should be performed in the areas
of welding and NDE to assess implementation of the
licensee's program,
b. Licensee Action
In addition to the SEP, the licensee should focus
additional management attention in the area of the licensed
operator requalification program to implement the necessary
actions to maintain a satisfactory program and to improve
the oversight of the program to ensure that the licensee
identifies programmatic problems rather that relying on the
NRC to identify the problems.
G. Safety Assessment /0uality Verification
I. Analysis
The assessment of this functional area includes all licensee
review activities associated with the implementation of licensee
tafety policies; licensee activities related to amendment,
exemption, and relief requests; response to NRC Generic Letters,
Bulletins, and Information Notices; and resolution of TMI items
and other regulatory initiatives. It also includes activities
related to the resolution of safety issues, 10 CFR Part 21
assessments, safety committee and self-assessment activities,
a alyses of industry's operational experience, root cause
analyses of plant events, use of feedback from plant quality
assurance (QA) and quality control (QC) reviews, and
participation in self-improvement programs. It includes the
effectiveness of the licensee's quality verification function in
identifying and correcting substandard or anomalous performance,
in identifying precursors of potential problems, and in
monitoring the overall performance of the plant.
This functional area was inspected on a routine basis by the NRC
resident inspectors, NRC region-based inspectors during
performance of the routine inspection program, and the OSTI
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team. The focus of the OSTI team was to perform a review of the
activities in this functional area that affected plant
operations.
The licensee was responsive to the need to provide necessary
support for license and amendment applications. Although the
quality of the request and supporting information for the
Cycle 12 reload application and approval of the internal vessel
monitoring system were adequate, actions were required by NRR to
obtain additional supplemental information so the NRC staff
could review the submittals. However, when the licensee
provided a response to NRC Generic Letter 88-17, " Loss of Decay
Heat Removal," it was noted that the submittal was timely, well
documented, and only minor clarifications were neces ary.
The licensee upgraded their capabilities to perform safety
assessments by expanding and strengthening the membership of the
PRC and the Safety Audit and Review Committee (SARC), the
licensee's offsite review group. The membership of the PRC was
changed to include individuals such as the Manager, Nuclear
Safety Review Group; Supervisor, Systems Engineering; and
Manager, Quality Assurance and Quality Control. The SARC
membership was changed by the addition of qualified outside
consultants that have had extensive experience in the operation,
management, and regulatory oversight of nuclear facilities. The
changes were viewed as a positive step toward increasing the
safety oversight capability of these two groups.
To provide an additional independent safety review of plant
problems, the licensee has established and staffed the Nuclear
Safety Review Group (NSRG). The function of this group is to
independently review plant events and other items as directed by
the Manager, NSRG. Based on the results of reviews, the NSRG
identifies root causes, makes recommendations for correction of
the problems, and verifies that the corrections are
appropriately implemented. The NSRG has performed reviews of
plant problems and issued a report on their findings. However,
all permanent members of the NSRG have not yet been selected and
trained. Due to the incomplete permanent staffing of the group,
a complete evaluation of the group's effectiveness could not be
performed during this assessment period.
In addition to formation of the NSRG, the licensee also
strengthened their capability for safety assessment and quality
verification by increasing the staff for the QA and QC
organizations from 19 to 27 personnel. A staffing increase of
seven personnel was also made in the nuclear licensing and
industry affairs group.
During this assessment period, reviews were performed of the I
activities of the onsite QA organization. The reviews revealed l
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that the audits and surveillance performed by the QA group were
compliance-oriented rather than based on an operational-safety
approach. Also noted during reviews of the QA program, was a
problem with the licensee's definition of significant
deficiencies. The threshold for identifying a deficiency as
significant was established at such a high level by the licensee
that deficiencies were rarely classed as significant. For this
reason, the additional management review required for
significant deficiencies was not being performed.
LERs adequately described the major aspects of each event,
including component or system failures that contributed to the
event and the significant corrective actions taken or planned to
prevent recurrence. Although the reports are generally well
written and easy to understand, the quality of the reports could
be improved. During review of LERs, it appeared that the same
types of events are recurring which implies that inadequate
corrective actions are being taken in response to plant events.
During the previous assessment period, problems were noted in
the areas of commitment tracking and the implementation of
corrective actions to be taken in response to a plant event. It
appears that the licensee took adequate corrective actions to
address these issues since no problems were noted during this
assessment period.
Overall, it appears that the involvement and oversight by
management of the activities related to this functional area
were evident with indications of prior planning and assignment
of priorities. However, there were a large number of LERs and
violations in this functional area as compared with the other
areas. Corrective actions were usually taken but weak rest
cause determinations occasionally resulted in repetition of
events. The licensee's resolution of technical issues indicated
that issues were clearly understood, conservative, timely
completed, and technically sound. With respect to
responsiveness to NRC initiatives, the licensee's actions were
timely, generally sound and thorough, and acceptable resolutions
were generally provided. The licensee's efforts to increase the
staffing in the organizations responsible for the performance of
activities in this area is notable. It is apparent that
experienced and knowledgeable personnel have been added to the
licensee's staff.
2. Performance Rating
The licensee is considered to be in Performance Category 2 in
this functional area.
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3. Recommendations
'
'a . .'NRC Actions
The level of NRC inspection effort in this functional area
should be consistent with the core _' inspection program. In.
addition, NRC inspecti_ons should be conducted.on the
licensee's audit program.
b. Licensee Actions
The licensee should provide additional management attention-
to:the completeness and technical' content of submissions
made, to NRR . in response .to NRC-identif.ied initiatives. and..
TS ' amendment. requests initiated by the licensee.
Additional management attention'is required to ensure that
appropriate corrective actions are'taken as a' result of'
E plant events. Licensee management should provide timely
training and staffing of the NSRG to provide an independent
review group to address the root causes of plant problems.
V. . Supporting Data and Summaries
A .- , Enforcement Activity
Th'e SALP Board reviewed the enforcement history for the period of
May 1, 1988, through April 30, 1989. The review included the
deviations, violations, and emergency preparedness weaknesses
provided'in Table 1. Escalated enforcement conferences, and the
results, held during this assessment period are listed below:
On June 8,1988, an enforcement conference was held to discuss.
the issues related to installation of inadequate check valves
for the air accumulators for the SIRWT level controllers. Also
discussed at this meeting, was the loss of containment integrity
due to a cap missing on an instrument test tee. As a result.of
this meeting, two Severity Level III violations were issued with ,
an aggregate Civil Penalty of $50,000. -l
On August 11, 1988, an enforcement conference was held to
discuss the issues related to the license'e's submittal of
nonconservative thermal margin / low pressure (TM/LP) setpoints
for the Cycle 11 operating cycle. As a result of the
conference, one Severity Level III and one Severity Level IV
violation were issued. No civil penalty was imposed.
On February 24, 1989, an enforcement conference was held to
discuss the concerns related to radiological control practices.
As a result of the enforcement conference three violations were
issued: two Severity Level IV and one Severity Level V.
I
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On April 12, 1989, an enforcement conference was held to discuss
problems identified in the area of security. The results of the
conference had not been published by the end of this assessment
period.
1
B. Confirmatory Action Letters
On July 11, 1988, a confirmatory action letter was issued to document
the actions to be taken by the licensee to address the
nonconservative TM/LP setpoints generated for the Cycle 11 operating
cycle.
C. 10 CFR Part 21 Reports Submitted by Licensee
No Part 21 reports were submitted by the licensee during this
assessment period.
l-
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TABLE 1
ENFORCEMENT ACTIVITY
NO. OF VIOLATIONS ENFORCEMENT
FUNCTIONAL .
IN SEVERITY LEVEL ACTION
AREA WEAKNESSES (1) DEV V IV III NOT ISSUED
A. Plar,t Operations 4(2)
B. Radiological Controls 1 4 !
C. Maintenance / Surveillance 1 6(2) 1 2
0. Emergency Preparedness 15
E. Security 7 6
F. Engineering / Technical 2 2 19 2
Support
G. Safety Assessment / Quality 11
Verification
TOTAL 15 2 4 51 3 8
(1) Applicable only to the emergency preparedness program.
(2) Includes Violation 285/8913-01 which has an example in both Plant Operations
and Maintenance / Surveillance
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